Job Description

ROLE PURPOSE: The Regional Ethics & Compliance Officer (RECO) plays a critical role in ensuring that the Aspen's business activities across the assigned region comply with all relevant Aspen policies, procedures, ethical standards, and applicable laws.

The RECO must have an in-depth knowledge of the pharmaceutical industry and specific business activities undertaken by Aspen in the region. He/she must always fully understand AspenaEUR(TM)s business' goals (group and regional), as well as the broader industry standards.

The RECO works closely with regional leadership teams and enablement functions to drive a culture of integrity and compliance within the region. They will lead and manage the execution of AspenaEUR(TM)s ethics & compliance programme in the region, investigate potential violations (where required), and provide guidance on ethical matters to safeguard AspenaEUR(TM)s reputation and mitigate risks. The RECO maintains a high level of independence to effectively oversee and manage regional ethics and compliance matters without undue influence from business or operational priorities. The RECO will therefore have a direct reporting line to the Group Head: Ethics & Compliance, ensuring that he/she is empowered to act without fear of retaliation and that all ethics & compliance issues, risks, and concerns are escalated appropriately and receive the necessary attention in accordance with the BoardaEUR(TM)s mandate and delegation of authority.

KEY PERFORMANCE AREAS: Ethics & Compliance Program Development and Implementation: Implement and maintain a regional ethics and compliance program in alignment with the Group ethics & compliance program & Group policies across the EME businesses, harmonizing practices across diverse regulatory environments. Ensure that local laws and regulations are incorporated into the EMEaEUR(TM)s ethics & compliance framework. Monitor and assess the effectiveness of the ethics & compliance program, recommending adjustments or improvements as needed. Risk Management and Monitoring: Identify, evaluate, and mitigate regional ethics & compliance risks, including those related to anti-bribery, anti-corruption, data protection, healthcare regulations, and international trade regulations. Conduct regular audits and assessments of regional operations to ensure adherence to ethics & compliance standards. Maintain a risk register and monitor evolving compliance and ethical risks specific to the pharmaceutical industry. Work closely with the AspenaEUR(TM)s Enterprise Risk Management (ERM) team to integrate ethics and compliance risks into the broader regional risk management framework. Training and Awareness: Prepare annual training schedules for employees and relevant third parties. Develop and deliver training to employees at all levels (such as Ethical Leadership training and other where face to face engagement is necessary or preferable). Conduct regular awareness campaigns about ethics & compliance issues with the aim of developing employees practical understanding and acumen in the relevant areas (e.g., conflicts of interest, gift & hospitality guidelines, reporting mechanisms). Ensure that new hires undergo mandatory ethics and compliance training as part of their onboarding. Investigation and Reporting: Under the direction of the Group Investigations Manager, investigate (as required) potential ethical violations, including fraud, conflicts of interest, and regulatory breaches. Collaborate with the appropriate counterparts on disciplinary actions, investigations, and reporting of violations. Report ethics & compliance issues to Group Head: Ethics & Compliance and ensure timely corrective actions are taken. Collaboration and Stakeholder Engagement: Visible key participant in strategic business discussions of EME. Serve as a trusted advisor to regional business leaders, offering guidance on compliance issues and ethical dilemmas. Collaborate with the Group Ethics & Compliance team to align regional activities with global strategies. Work with cross-functional teams, including legal, HR, marketing, sales, and operations, to ensure that ethical considerations and compliance are embedded in all business processes. Key role player in the EME Integrity Committee, providing guidance and direction on adherence to ethics and compliance standards. Regulatory Affairs and Reporting: Stay updated on regional legal and regulatory developments affecting the region, including healthcare regulations and anti-corruption laws. Prepare and submit required reports and documentation to Group. Ethics & Compliance Communication: Promote transparent communication of AspenaEUR(TM)s ethical standards and compliance policies. Ensure that the companyaEUR(TM)s Code of Conduct and related policies are easily accessible and clearly understood by employees (reviewing translated documents for accuracy). Foster a culture of ethics & compliance through open and effective communication channels. Ethics & Compliance Audits: Support internal or external auditors on audits conducted and monitor CAPA implementation by the relevant EME business. Review the effectiveness of internal controls and provide recommendations for improvements to mitigate any identified ethics & compliance risks. Financial: Manage the regional ethics & compliance budget, including allocation of resources for training, audits, and investigations. Human Capital: Provide leadership and development support to any direct reports, including performance management, coaching, and succession planning, to build a high-performing regional ethics & compliance function. Oversee and lead the Assistant RECOs to ensure effective and timely execution of their functions in the relevant business units.

ADDITIONAL RESPONSIBILITIES: Enterprise Risk Management Process (ERMP): Engage with business leaders and key stakeholders within EME to identify and evaluate and rate strategic risks and agree mitigations on a quarterly basis. Maintain the strategic risk register for the EME businesses. Submit Quarterly ethics & compliance risk assessments and strategic risk registers for review in accordance with the ERMP. Business Continuity Management Process: Support the development and implementation of EMEaEUR(TM)s BCMP.